IR-6: Incident Reporting

The ir-6: incident reporting requirement means you must require all personnel to report suspected security incidents to your incident response function within an organization-defined timeframe, then ensure the report reliably reaches the people and tools responsible for triage and response. Operationalize it by defining what “suspected incident” means, publishing simple reporting paths, training users, and retaining proof that reporting works in practice.

Key takeaways:

• Define and publish a clear internal reporting deadline (“within X”) and make it realistic for staff to follow.
• Provide multiple reporting channels (ticketing, hotline, SOC email, chat) with monitored coverage and escalation.
• Retain evidence that people were trained, reports were received on time, and triage started promptly.

IR-6 is a speed-and-reliability control. It does not ask you to “stop incidents.” It asks you to make sure the organization finds out quickly when something might be wrong, because every downstream incident response activity depends on that first report. The control is deceptively short, and that’s where teams get burned: auditors and assessors will look for proof that your reporting expectation is defined, communicated, and followed, not just written in a policy.

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing IR-6 is to translate the requirement into three concrete design decisions: (1) the internal clock (your “within X” reporting timeframe), (2) the reporting routes (how personnel report), and (3) the receiving capability (who monitors, triages, and escalates). Then you attach evidence to each step: training completion, reporting job aids, inbox/ticket logs, and incident intake metrics pulled from the system of record.

IR-6 commonly intersects with third-party operations, too. Contractors, managed service providers, and other third parties often see suspicious activity first. Your reporting rule has to cover them contractually and operationally, or you will have a gap between “policy” and “practice.”

Regulatory text

Excerpt (IR-6): “Require personnel to report suspected incidents to the organizational incident response capability within {{ insert: param, ir-06_odp.01 }} ; and” ¹

What the operator must do:

1. Set an organization-defined reporting timeframe (the parameter placeholder is where your program inserts “within X”). Your timeframe must be explicit and communicated to personnel. ¹
2. Require personnel to report suspected incidents (not only confirmed incidents). This requirement must apply to the people who use, administer, or support the system. ¹
3. Route reports to the incident response capability (SOC, IR team, security operations, or another defined function) so intake is monitored and actionable. ¹

Reference: NIST SP 800-53 Rev. 5 control family IR ²

Plain-English interpretation (what IR-6 is really asking)

You need a functioning “early warning” mechanism:

• People must know what to report (phishing, lost devices, suspicious logins, data sent to the wrong recipient, malware alerts, odd system behavior).
• People must know how to report (one or more simple channels).
• Your IR capability must receive and act (triage and escalation).
• You must be able to prove it works using records from the tools people actually use.

A practical way to frame IR-6 for the business: “If you suspect something is wrong, report it fast through these channels. We will triage it, and you will not be penalized for good-faith reporting.”

Who it applies to (entity + operational context)

IR-6 applies to organizations implementing NIST SP 800-53 controls, including:

• Federal information systems and programs assessed against NIST SP 800-53. ²
• Contractor systems handling federal data, where NIST SP 800-53 is flowed down via contract, agency requirements, or an assessment boundary. ²

Operationally, it applies anywhere personnel could observe or generate incident signals:

• Corporate endpoints, email, collaboration tools, and VPN
• Production workloads, admin consoles, and CI/CD
• Help desk and IT operations (often the first to hear “something is weird”)
• Third-party support channels (MSP/MSSP, SaaS support, outsourced call centers)

What you actually need to do (step-by-step)

Step 1: Assign ownership and define the “incident response capability”

• Name a control owner (often the IR manager, SOC lead, or CISO delegate) and a GRC owner accountable for evidence readiness.
• Define the system of record for incident intake (SIEM/SOAR platform, ticketing system, dedicated IR queue).
• Document who monitors it, with on-call coverage expectations that match your risk.

Deliverable: IR-6 control narrative mapped to owner, process, and evidence artifacts ¹

Step 2: Define “suspected incident” for reporting purposes

Keep the definition short and example-driven. Include:

• Suspicious email or link clicks, credential prompts, MFA push fatigue
• Lost/stolen devices, badges, removable media
• Accidental data exposure (mis-sent email, public link sharing, wrong permissions)
• Unexpected system behavior (new admin accounts, unknown processes, unusual access prompts)

Tip: If employees must decide whether it is “real” before reporting, you will get late reports. Treat uncertainty as a reason to report.

Step 3: Set the reporting timeframe (“within X”)

The control requires an organization-defined timeframe ¹. Pick a value you can defend operationally:

• Align to how quickly you expect staff to notice and act (front-line staff vs. admins vs. on-call engineers).
• Make it consistent with monitoring coverage and triage capacity.
• Use the same “clock start” definition everywhere (e.g., “from discovery” or “from suspicion”).

Documentation requirement: Publish the timeframe in the incident reporting SOP and training materials, not only in a policy.

Step 4: Build simple reporting paths (at least two)

Common patterns that survive audits:

• “Report phishing” button that generates a ticket and attaches headers
• Dedicated email alias that auto-creates a case
• Hotline/chat channel for urgent issues
• Help desk workflow with mandatory security escalation fields

Control test: Can a new hire find the reporting path in under a minute without asking their manager?

Step 5: Make intake actionable (triage + escalation)

Define minimum intake fields:

• Reporter name/contact, time of discovery, system/app, what was observed, screenshots/log snippets
• Data involved (if known), third parties involved (if any), business impact guess (if any)

Define triage rules:

• Severity rubric or routing decision tree (phishing vs. device loss vs. unauthorized access)
• Escalation triggers to legal/privacy, HR, and business owners
• Hand-off to forensics, IAM, IT ops, or third-party management

Step 6: Train personnel and validate behavior

• Add incident reporting training to onboarding and recurring security training.
• Run phishing simulations or tabletop exercises that include “report suspected incident within X.”
• Verify that reports are arriving through the documented channels and are being triaged.

Step 7: Operationalize third-party reporting

If third parties operate systems or handle federal data on your behalf:

• Contractually require reporting of suspected incidents to your incident response capability within your timeframe (or faster if you need it).
• Provide them the same reporting channels (or an agreed secure channel).
• Test the path during onboarding and at least annually through an exercise.

Step 8: Set up evidence automation (where Daydream fits naturally)

Most IR-6 gaps are evidence gaps: the work happens in email, chat, and tickets, but the audit binder has only a policy. Daydream can help you map IR-6 to the real control owner, link the incident intake system of record, and schedule recurring evidence pulls (training completion, ticket queue exports, and incident intake timestamps) so you are not reconstructing timelines under pressure.

Required evidence and artifacts to retain

Use this as your audit-ready checklist:

Governance

• IR-6 control narrative (scope, owner, tools, reporting timeframe) ¹
• Incident Reporting SOP (how to report, what to report, required fields)
• Role-based responsibility matrix (SOC/IR, help desk, legal/privacy, communications)

Operational proof

• Screenshots/config exports of reporting channels (phish button config, ticket queue rules, aliases)
• Ticketing/IR platform records showing:
  • report receipt time
  • triage start time
  • assignment/escalation history
• Training records (course content referencing reporting timeframe; completion logs)

Testing

• Tabletop or simulation materials with after-action notes that include reporting behavior
• Periodic sampling results: reported events traced from initial report to IR intake

Common exam/audit questions and hangups

1. “Show me your ‘within X’ requirement and where it is communicated.” Auditors expect consistency across policy, SOP, and training. ¹
2. “How do contractors report?” If contractors are in scope, they must be covered operationally, not only contractually. ²
3. “Prove personnel actually reported suspected incidents.” They will ask for recent tickets/cases and trace the timeline from discovery to intake.
4. “What happens if the report goes to the help desk?” You need a defined escalation path into the incident response capability. ¹

Frequent implementation mistakes (and how to avoid them)

• Mistake: “Report incidents” policy without “suspected incidents” language. Fix by explicitly including suspicion-based reporting and examples. ¹
• Mistake: Deadline is defined but not operationalized. Fix by embedding the timeframe in training, job aids, and the report form.
• Mistake: Single reporting channel. Fix by adding at least one fallback channel and monitoring both.
• Mistake: No system of record. Fix by forcing email/chat reports to open a ticket/case automatically.
• Mistake: Third parties excluded. Fix by adding reporting obligations to contracts and onboarding checklists for in-scope third parties.

Risk implications (why assessors care)

Late or missing reporting creates avoidable exposure:

• You cannot contain what you do not know about.
• You lose forensic context (logs roll, devices change state, credentials get reset).
• Regulatory and contractual reporting obligations often depend on internal detection and escalation timing; IR-6 supports that upstream workflow without substituting for breach notification laws.

Practical execution plan (30/60/90-day)

First 30 days (stabilize the requirement)

• Assign IR-6 control owner and confirm the incident response capability and system of record.
• Define “suspected incident” examples and publish a one-page reporting job aid.
• Choose and document the “within X” reporting timeframe in the SOP and training materials. ¹

Days 31–60 (make it operational)

• Implement or harden reporting channels (phish button, alias-to-ticket, hotline/chat).
• Configure triage workflow, required fields, and escalation rules to legal/privacy and IT.
• Run a small internal campaign: “How to report suspected incidents” with screenshots and links.

Days 61–90 (make it provable)

• Conduct a tabletop or simulation that tests whether users report via the documented channel and whether the IR team receives it inside the timeframe requirement.
• Start recurring evidence capture (training logs, ticket exports, case timestamps) in a central repository; Daydream can track owners and automate evidence reminders tied to IR-6.
• Sample recent reports and document lessons learned, including any missed reports and corrective actions.

Frequently Asked Questions

Do I need to require reporting of “suspected” incidents, or only confirmed incidents?

IR-6 explicitly requires reporting of suspected incidents to the incident response capability within your defined timeframe ¹. Treat uncertainty as reportable to avoid late escalation.

How do I choose the “within X” reporting timeframe?

Pick a timeframe your workforce can follow and your IR function can support, then document it consistently in SOPs and training ¹. Auditors mainly test clarity, communication, and whether your records show timely reporting.

Does a help desk ticket count as “reporting to the incident response capability”?

It can, if the help desk workflow reliably routes suspected incidents into the IR intake queue and the IR team monitors that queue ¹. Prove it with routing rules and ticket history.

Are contractors and other third parties included?

If they are personnel supporting in-scope systems or handling federal data in your boundary, you need a workable reporting path for them ². Contract language helps, but assessors also look for operational onboarding and tested channels.

What evidence is most persuasive in an assessment?

Time-stamped intake records from the system of record (tickets/cases) that show receipt and triage, plus training records that teach the reporting requirement. A policy alone rarely closes IR-6.

How should I handle “false alarms” so people keep reporting?

Write and socialize a non-punitive expectation for good-faith reporting, then keep the intake form short and the response courteous. If you punish noisy reports, you will suppress the signal you need for IR-6.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5